ML25035A302
| ML25035A302 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/04/2025 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25035A300 | List: |
| References | |
| ULNRC-06917 | |
| Download: ML25035A302 (1) | |
Text
Attachment 1 (Attachment 1 to Enclosure to ULNRC-06902)
Proposed Technical Specification Changes (Mark-up)
(Page 1 of 5)
INo change this page.
j Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.19 Risk Informed ComDletion Time Proaram This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS)
Guidelines. The program shall include the following:
a.
The RICT may not exceed 30 days; b.
A RICT may only be utilized in MODE I and 2; C.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
I.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
3.
Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.
d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
(continued)
CALLAWAY PLANT 5.0-23 Amendment No. 229
5.5_Programs and Manuals 5.5.19 Programs and Manuals 5.5 e.
A RICT calculation must include the following hazard groups:
. Internal Events PRA (IEPRA) model (includes internal floods)
. Internal Events Fire PRA (FPRA) model
. High Winds PRA (HW PRA) model Changes to these means of assessing the hazard groups require prior NRC approval.
f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities.
- g. A report shall be submitted in accordance with Specification 5.6.11 before a newly developed method is used to calculate a RICT.
Risk Informed Com letion Time Pro ram (continued) e.
The rick acoecoment approaoheo and methode ohall be aooeptable to the NRC. The plant PRA ohall be based on the ac built, ac operated, and maintained plant; and reflect the operating experience at the plant, ac opeoified in Regulatory Guide 1.200, Revision 2. Methods to accooc tho rick from extending the Completion Times must be PRJ\\ methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
CALLAWAY PLANT 5.0-24 Amendment No. 229
5.6 Reporting Requirements (continued)
Reporting Requirements 5.6 5.6.10 Steam Generator Tube Inspection Report a.
The scope of inspections performed on each SG; b.
The nondestructive examination techniques utilized for tubes with increased degradation susceptibility; c.
For each degradation mechanism found:
I The nondestructive examination techniques utilized; 2.
The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported; 3.
A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and 4.
The number of tubes plugged during the inspection outage; e.
The number and percentage of tubes plugged to date, and the effective plugging percentage in each steam generator; and A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 5.5.9, Steam Generator (SG) Program. The report shall include:
V
/
d.
An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results; (continued)
CALLAWAY PLANT 5.0-29 Amendment No. 2O
Insert 1, new TS Section 5.6.11 5.6. 1 1 Risk Informed Completion Time (RICT) Program Upgrade Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to the first use of those methods to calculate a RICT. The report shall include:
a.
The PRA models upgraded to include newly developed methods; b.
A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-1 9027-NP, Revision 2, Newly Developed Method Requirements and Peer Review; c.
Any open findings from the peer review of the implementation of the newly developed methods and how those findings were dispositioned; and d.
All changes to key assumptions related to newly developed methods or their implementation.